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Cayman: CIG Statement on Russia Sanctions

As a global partner and United Kingdom Overseas Territory (UKOT), the Cayman Islands affirms its commitment to helping maintain peace and security around the world. From the onset of the most recent Russian military action against Ukraine, both the people and Government of the Cayman Islands have expressed grave concern for the people of Ukraine and a desire for a peaceful resolution. 

On 22 February 2022, the Foreign, Commonwealth & Development Office (FCDO), which is responsible for the UK’s international sanctions policy, updated the UK Sanctions list on GOV.UK. The Russia (Sanction) (EU Exit) Regulations made pursuant to the Sanctions and Anti-Money Laundering Act 2018 (UK), also known as SAMLA, was extended to the Cayman Islands through an Order in Council. 

Thereafter, all designations made under the United Kingdom sanctions regulations and extended to the Cayman Islands, have immediate effect in the Cayman Islands once the relevant Order in Council comes into force.  

The Russia (Sanctions) (Overseas Territories) Order 2020 and The Russia (Sanctions) (EU Exit) Regulations 2019 (the Regulations), have been in force in the Cayman Islands since December 31, 2020.   Cumulatively these Regulations provide for, amongst other things, the freezing of funds and economic resources including assets such as aircraft, real estate and yachts of designated persons, entities or bodies involved in destabilising Ukraine, undermining or threatening its territorial integrity, sovereignty or independence, or obtaining a benefit from or supporting the Government of Russia. 

The UK has recently published a list of designated persons, entities or bodies pursuant to the Regulations, to be subject to sanctions. Since 22 February 2022 a total of 19 named individuals and 18 named entities have been included on the list. This list is also enforced in the Cayman Islands.

All Russia Sanction notices issued by HM Treasury’s Office of Financial Sanctions Implementation (OFSI) that are applicable to the Overseas Territories have been published by the Financial Reporting Authority (FRA), and the Cayman Islands Monetary Authority (CIMA). These notices have also been disseminated to all relevant industry stakeholders with specific obligations for compliance. FRA and CIMA, along with other relevant authorities, are responsible for disseminating the relevant notices. These sanction measures apply in the Cayman Islands in the same way they do in the United Kingdom.

Relevant Cayman Islands industry stakeholders are required by law to report to the FRA where there are activities that are impacted by the Russia sanctions. The Government has been assured by stakeholders that they have been actively monitoring the ongoing impact of sanction activities. 

Cayman Islands Government entities such as Maritime Authority of the Cayman Islands (MACI), General Registry, Civil Aviation Authority (CAA), Lands & Survey Department and CIMA have also been actively monitoring their respective books of business for any possible connections with persons/entities that are subject to the Russia sanctions.

The Cayman Islands is continuing to monitor the global situation and will issue updates primarily via the FRA and CIMA websites as advised by the FCDO.  The Cayman Islands Government stands ready to carry out the sanctions as extended by the UK.

QUOTES 

H.E. Governor Martyn Roper shared “The Government and people of the Cayman Islands are shocked by Putin’s invasion of Ukraine and are watching with horror as the conflict unfolds. The Cayman Islands has fully imposed all of the Russia sanctions and will continue to do so as the list of sanctioned individuals and entities grows. The Cayman Islands is fully committed to good governance, democracy and support of peace around the world”. 

Premier Hon. G. Wayne Panton said “Our Government joins the UK and its Overseas Territories in support of the people of Ukraine; it is our responsibility to enforce the Russia sanctions. We continue to hope and pray that this conflict is quickly and peacefully resolved to avoid further loss of innocent lives in Ukraine.” 

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